- 5 -
been engaged in a number of business ventures. He was employed
for 12 years in a supervisory capacity over several Super-X drug
stores located across Ohio, Indiana, and Kentucky. In
approximately 1979, he founded a tool and die business, which he
ran for about 3 years. Mr. Richardson obtained licenses to sell
insurance and mutual funds in around 1983 and maintained those
licenses until allowing them to expire sometime in the 1996 to
1998 timeframe. Each license required Mr. Richardson to attend
approximately 40 hours of classes and to pass an examination.
From 1993 to 1996, Mr. Richardson was self-employed as an
insurance salesman, operating through a sole proprietorship under
the name Benefit Planning Services.
Trust Implementation and Operation
In 1995, petitioners met with representatives from the Aegis
Company (Aegis), an entity that promoted both domestic and
foreign trust packages.2 Michael Vallone was the executive
director of Aegis, Robert Hopper was the managing director, and
Edward Bartoli (Mr. Bartoli)3 was the legal director.
Petitioners purchased a multitrust package from Aegis in 1996 for
2 Use of “trust”, “trustee”, “beneficiary”, and related
appellations is for convenience only and is not intended to
impart any legal significance with respect to characterization
for Federal tax purposes.
3 The parties do not dispute that Mr. Bartoli, although
formerly admitted to practice law in Illinois, was disbarred
subsequent to the years in issue in these cases.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011